EXPLANATION OF SIGNIFICANT DIFFERENCE (ESD) FOR ... · United States Department of Energy Savannah...
Transcript of EXPLANATION OF SIGNIFICANT DIFFERENCE (ESD) FOR ... · United States Department of Energy Savannah...
United States Department of Energy
Savannah River Site
Explanation of Significant Difference (ESD) for Incorporating Tank 12 into the Revision 1 Interim Record of Decision Remedial Alternative Selection for the H-Area Tank Farm, Waste Tank 16
CERCLIS Number: 89
SRR-CWDA-2016-00107
Revision 0
December 2016
Prepared by: Savannah River Remediation (SRR) Savannah River Site Aiken, SC 29808 Prepared for U.S. Department of Energy Under Contract No. DE-AC09-09SR22505 •
11066122
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DISCLAIMER
This document was prepared in conjunction with work accomplished under Contract No. DE-AC09-09SR22505 for the U.S. Department of Energy. This work was prepared under an agreement with and funded by the U.S. Government Neither the U.S. Government or its employees, nor any of its contractors, subcontractors or their employees, makes any express or implied: 1. warranty or assumes any legal liability for the accuracy, completeness, or for the use or results of such use of any information, product or process disclosed; or 2. representation that such use or results of such use would not infringe upon privately owned ri^ts; or 3. endorsement or recommendation of any specificaUy identified commercial product process, or service. Any views and opinions of authors expressed in this work do not necessarily state or reflect those of the United Sutes Government, or its contractors, or subcontractors.
Printed in the United States of America
Prepared for U.S. Department of Energy
and Savannah River Remediation, LLC
Aiken, South Carolina
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TABLE OF CONTENTS
LIST OF FIGURES ii
LIST OF ACRONYMS. iii I. INTRODUCTION 1
II. SITE HISTORY AND SELECTED REMEDY 2
III. BASIS FOR THE EXPLANATION OF SIGNIFICANT DIFFERENCE 5 IV. DESCRIPTION OF SIGNIFICANT DIFFERENCE 5
V. STATUTORY DETERMINATIONS 6
VI. PUBLIC PARTICIPATION 6 VII. REFERENCES 6
LIST OF FIGURES
FIGURE 1. LOCATION OF THE SAVANNAH RIVER SITE 8
FIGURE 2. LAYOUT OF THE GENERAL SEPARATIONS AREA 9
FIGURE 3. GENERAL LAYOUT OF THE H-AREA TANK FARM 10
FIGURE 4. CROSS-SECTIONAL VIEW OF TYPICAL HTF TYPE I TANK 10
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LIST OF ACRONYMS
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
ESD Explanation of Significant Difference
FFA Federal Facility Agreement
HTF H-Area T ank Farm
ICMI/RAIP Interim Corrective Measures Implementation/Remedial Action Implementation Plan IROD Interim Record of Decision
LLC Limited Liability Company
LUC Land Use Control
NCP National Oil and Hazardous Substances Pollution Contingency Plan
OU Operable Unit
RA Remedial Action
RCRA Resource Conservation and Recovery Act
ROD Record of Decision
SCDHEC South Carolina Department of Health and Environmental Control
SRR Savannah River Remediation, LLC
SRS Savannah River Site
USDOE United States Department of Energy
USEPA United States Environmental Protection Agency
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I. INTRODUCTION
This Explanation of Significant Difference (ESD)
is being issued by the United States Department of
Energy (USDOE), which functions as the lead
agency for Savannah River Site (SRS) remedial
activities, with concurrence by the United States Environmental Protection Agency (USEPA) and
the South Carolina Department of Health and
Environmental Control (SCDHEC). The purpose
of this ESD is to announce the incorporation of
Waste Tank 12 at the H-Area Tank Farm (HTF)
into the interim response action selected in the
Interim Record of Decision Remedial Alternative
Selection for the H-Area Tank Farm, Waste Tank 16 (SRR-CWDA-2015-00157).
Under the Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLA) Section 117(c), SRS is required to
publish an ESD whenever there is a significant
change to a component of a remedy specified in a
Record of Decision (ROD). Sections
300.435(c)(2Ki) and 300.825(aX2) of the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP) require the lead agency to
provide an explanation of the difference and to
make this information available to the public in the
Administrative Record File and information
repositories.
USDOE manages certain waste materials at the
SRS that are regulated under the Resource
Conservation and Recovery Act (RCRA), a
comprehensive law requiring responsible
management of hazardous waste. USDOE
received a RCRA hazardous waste permit from the
SCDHEC, which was most recently renewed on
February 11, 2014. Module VIII of the Hazardous
and Solid Waste Amendments portion of the
RCRA permit mandates corrective action
requirements for non-regulated solid waste
management units subject to RCRA 3004(u). The
SRS Federal Facility Agreement (FFA) lists the
HTF as a RCRA/CERCLA Operable Unit (OU).
The SRS FFA, Section IX.E, addresses the
eventual removal of waste tanks and ancillary equipment ftom service and any appropriate
CERCLA response action relating to the waste tank
systems (WSRC-OS-94-42).
The USDOE intends to remove from service the
waste tanks that do not meet the standards established in Appendix B (High Level
Radioactive Waste Tank Systems) of the SRS FFA,
pursuant to Section 120 of CERCLA and Sections
3008(h) and 6001 of RCRA, as amended by the
Hazardous and Solid Waste Amendments of 1984
(hereafter jointly referred to as RCRA) and the Atomic Energy Act of 1954. Until the HTF waste
tanks and ancillary equipment are removed from
service, they are regulated under the Industrial
Wastewater Construction Permit #17,424-1W,
issued to SRS under the South Carolina Pollution
Control Act, S. C. Code Ann., Section 48-1-10, et
seq. (DHEC_01-25-1993) and applicable regulations implementing that Act. Waste tanks
and ancillary structures are removed from the
conditions of Industrial Wastewater Construction
Permit #17,424-IW when operationally closed and
removed from service in accordance with an
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approved HTF General Closure Plan and waste
tank system-specific Closure Module.
The Interim ROD (IROD) for HTF Waste Tank 16
selected Annual Visible Engineered Barriers
Inspection and Maintenance. The interim action is
limited to any maintenance deemed necessary from
the annual inspections from the time of removal of
a waste tank or associated ancillary equipment
from service until a final ROD is issued for the
HTF OU. The IROD explained that an ESD would be used to incorporate the interim remedy for
additional HTF waste tanks, group of waste tanks, and associated ancillary structures when
satisfactorily removed from service in accordance
with a SCDHEC approved closure module.
USDOE has submitted and implemented an HTF General Closure Plan (SRR-CWDA-2011-00022),
the Waste Tank 12 Closure Module (SRR-CWDA-
2014-00086) and the Addendum to the Waste Tank 12 Closure Module (SRR-CWDA-2015-00074)
that describes the waste removal, characterization
of residuals, associated risk, and stabilization of the
waste tanks. This ESD incorporates HTF Waste
Tank 12 into the interim remedy selected in the
IROD.
This ESD is part of the Administrative Record File
and is available for public review during normal
business hours at the following repositories.
US Department of Energy Public Reading Room Gregg-Graniteville Library University of South Carolina - Aiken 171 University Parkway Aiken, South Carolina 29801 (803)641-3465
Thomas Cooper Library Government Documents Department University of South Carolina Columbia, South Carolina 29208 (803) 777-4866
11. SITE fflSTORY AND SELECTED REMEDY
This ESD documents the incorporation of HTF Waste Tank 12 into the selected interim response
action for the HTF waste tanks and ancillary
equipment as found in the Interim Record of
Decision Remedial Alternative Selection for the H-
Area Tank Farm, Waste Tank 16 (SRR-CWDA-
2015-00157). After the ESD is signed and issued
to the public, an interim Remedial Action (RA)
Start notification letter for HTF Waste Tank 12 will be submitted to SCDHEC and USEPA to
notify the agencies that the interim RA is initiated.
H-Area Tank Farm
The HTF is located at the SRS in Aiken County
and Barnwell County, South Carolina (Figure 1).
The HTF is a 45-acre site within the General
Separations Area, which encompasses E-, F-,
H-, J-, S-, and Z-Areas (Figure 2). HTF consists of
29 liquid waste storage tanks, three evaporator
systems, over 74,800 linear feet of transfer
pipelines, eight diversion boxes, one catch tank,
two concentrate transfer system tanks and ten
pump pits. Figure 3 shows the general layout of
HTF. There are four major waste tank types in
HTF that range in size from 750,000 gallons (Type
I tanks) to 1.07 million gallons (Type II tanks) to
1.3 million gallons (Type Ill/IIIA and Type IV
tanks) that have varying degrees of secondary
containment and intra-tank interference, such as
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cooling coils and columns. HTF was constructed
to receive waste generated by various SRS
production, processing, and laboratory facilities.
The use of HTF isolated these wastes from the
environment, SRS workers, and the public. With HTF and its sister facility, F-Area Tank Farm,
facilities are in place to pretreat the accumulated sludge and salt solutions (supemate) to enable the
management and treatment of these wastes within
other SRS facilities (i.e.. Defense Waste Processing
Facility and Saltstone Production Facility). These treatment facilities convert the sludge and
supemate to more stable forms suitable for permanent disposal in a Federal Repository or the
Saltstone Disposal Facility, as appropriate.
HTF Waste Tank 12 is a Type I tank constructed in
the early 1950s. These waste tanks are 75 feet in
diameter and 24.5 feet high, with a nominal
operating capacity of 750,000 gallons. The
primary liner of Type I waste tanks is made of 0.5-
inch thick carbon steel. The 0.5-inch thick carbon
steel waste tank top and bottom were joined to the
walls with non-stress-relieved welded knuckle
plates made of the same material. Figure 4
provides a cross-section of a typical HTF Type I waste tank.
The carbon steel shell sits inside a 22-inch thick
reinforced concrete vault with a 2.5-foot annular
space surrounding the primary tank. Lining the
bottom of the vault for secondary containment is a
5-foot high, 0.5-inch thick carbon steel secondary
liner (annulus pan) to collect leakage, if any, from
the primary tank. A dehumidification ductwork
system was installed on the secondary liner floor to
keep the annular space dry by circulating warm air
at a temperature above its dew point.
Dehumidification equipment consisting of an
above-ground heater and fan connect to the
ductwork inlet via an annulus inlet riser.
The waste tank tops are approximately nine feet
below grade. Each Type I waste tank has twelve
concrete filled steel columns to support the roof. These columns have an outer diameter of two feet,
and are 0.5-inch thick carbon steel pipe filled with
concrete and welded to the top and bottom of the
primary tank. Cooling coils in Type I waste tanks are configured in both a horizontal and a vertical
array, which creates obstacles to waste removal
and other activities inside the waste tank. There
are approximately 22,800 linear feet of 2-inch Schedule 40 carbon steel pipe cooling coils in a
Type I waste tank. [SRR-CWDA-2010-00128]
H-Area Tank Farm Closure Activities
HTF Waste Tank 12 was operationally closed and
removed from service on April 28, 2016 in
accordance with an approved HTF General Closure
Flan (SRR-CWDA-2011-00022), a waste tank system-specific Closure Module (SRR-CWDA-
2014-00086) and an Addendum to the waste tank system specific Closure Module (SRR-CWDA-
2015-00074). No ancillary structures were
included in the removal from service of HTF
Waste Tank 12. The waste tank was isolated from
the remaining operating facility and filled with
grout (i.e., stabilized). Some equipment installed
in the waste tank or used in the closure activities
(e.g., submersible transfer pump, steam Jets,
thermowells) were entombed in the grout as part of
the stabilization process.
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USDOE is in the process of removing the
remaining HTF waste tanks and ancillary structures
fiom service in accordance with the HTF General
Closure Plan (SRR-CWDA-2011-00022) and
waste tank system-specific closure modules. HTF
waste storage and removal operations are governed
by Industrial Wastewater Construction Permit
#17.424-rW issued by SCDHEC on January 25,
1993 (DHEC_01-25-1993) and the FFA. The State
of South Carolina has authority for approval of
wastewater treatment facility operational closure under Chapter 61, Article 82 of the SCDHEC
Regulations. The Ronald Reagan National
Defense Authorization Act (NDAA) for Fiscal Year
2005, Section 3116 (a) specifies the criteria for
USDOE to use to determine whether residuals
remaining in the waste tank systems can be managed as non-high level waste at a USDOE site
in a "covered state" (e.g.. South Carolina) where
activities are regulated by the state's approved
closure plan or permit, authonty for the approval or
issuance of which is conferred on the State outside
of Section 3116. The Basis for Section 3116
Determination for Closure of H-Tank Farm at the
Savannah River Site (DOE/SRS-WD-2014-001) was prepared for HTF, based in part on the
environmental protection information provided in
the Perffarmance Assessment for the HTF at SRS
(SRR-CWDA-2010-00128). Based on the
information in the Section 3116 Basis Document
and the performance assessment, the Secretary of
Energy, in consultation with the Nuclear
Regulatory Commission, determined that the
residual material in the waste tank systems could
be managed as non-high level waste.
In accordance with the SRS FFA, when all HTF
waste tanks and ancillary structures have been
removed from service, an appropriate response
action will be developed for the HTF OU, which
includes the stabilized waste tanks and ancillary
structures as well as the surrounding environmental
media and groundwater directly below the HTF.
The HTF General Closure Plan requires monitoring
of the groundwater under an approved HTF
Groundwater Monitoring Plan, which describes the
monitoring of the groundwater exiting the HTF.
The Groundwater Monitoring Plan supports both
the operation and removal fiom service of the HTF
waste tanks and includes requirements for
reporting the monitoring results. [SRNS-RP-2012-
00146] The HTF Groundwater Monitoring Plan remains in effect until all waste tanks have been
removed from service, at which time a remedial
decision will be made for the HTF OU which
includes the stabilized tanks, the surrounding soils
and the groundwater below the HTF. Because
these monitoring requirements are already in place,
groundwater monitoring is not a part of this interim
action.
Selected Remedy
This ESD documents the incorporation of HTF
Waste Tank 12 into the selected interim response
action for the HTF Waste Tank 16.
The selected remedy. Annual Visible Engineered
Barriers Inspection and Maintenance, includes
annual inspections of the engineered barriers (e.g.,
visible grout) for physical integrity. In addition,
the area will be inspected for excessive water
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accumulation that may cause premature
degradation of the engineered barriers associated
•with stabilization of the waste tanks. The interim
action is limited to any maintenance deemed
necessary from the annual inspections from the
time of removal of a waste tank or associated
ancillary equipment from service until a final ROD is issued for the HTF OU. This alternative was
selected because it is protective of human health and the environment, and the requirement for
annual inspections is consistent with the
maintenance and monitoring requirements of the
HTF General Closure Plan and the waste tank
system-specific closure module.
An Interim Corrective Measures
Implementation/Remedial Action Implementation
Plan (ICMI/RAIP) was prepared to include all
waste tanks in the HTF tha,t are in the IROD and
subsequent ESDs. The ICMI/RAIP initially included Waste Tank 16. [SRR-CWDA-2016-
00095] As additional waste tanks in HTF are
closed, an ESD will be used to apply the interim remedy selected in the IROD to those HTF waste
tanks and associated ancillary structures removed
from service. Because there is no change to the
implementation of the interim remedial action
selected in the IROD, the ESD will also refer to the
same ICMI/RAIP for implementation of the
selected remedy.
The current land use for the HTF is industrial with
USDOE maintaining control of the land. The HTF
is currently in the operational phase and access is
controlled by SRS facility security and
administrative controls. Land use controls (LUCs)
are not part of the interim action. LUCs may be
included in the final ROD for the HTF OU in order
to prevent inadvertent exposure to remaining
contaminated media and to ensure the integrity of
the closed tanks by restricting land and
groundwater uses within the HTF OU. The Land
Use Control Implementation Plan will be deferred until final closure of the entire HTF OU.
ni. BASIS FOR THE EXPLANATION OF SIGNIFICANT DIFFERENCE
The purpose of this ESD is to document a post-
IROD change by incorporating HTF Waste Tank
12 into the selected interim remedial action for HTF Waste Tank 16 to include Annual Visible
Engineered Barriers Inspection and Maintenance.
HTF Waste Tank 12 has been operationally closed
and removed from service under an HTF General
Closure Plan (SRR-CWDA-2011-00022), a waste
tank system-specific Closure Module (SRR-
CWDA-2014-00086) and an Addendum to the
waste tank system specific Closure Module (SRR-CWDA-2015-00074). This waste tank will be
inspected and maintained until final closure of the
HTF OU.
IV. DESCRIPTION OF SIGNIFICANT DIFFERENCE
The same interim action remedy selected for HTF
Waste Tank 16 is applied to HTF Waste Tank 12.
The selected remedy. Annual Visible Engineered
Barriers Inspection and Maintenance, is protective
of human health and the environment and will comply with applicable federal and state laws. In
addition, it is consistent with the maintenance and
monitoring requirements of the HTF General
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Closure Plan and the waste tank system-specific
closure module. The addition of HTF Waste Tank
12 to the selected interim remedy does not impact
the cost of implementation.
V. STATUTORY DETERMINATIONS
The addition of HTF Waste Tank 12 to the interim
remedial action enhances protection of human
health and the environment, complies with federal
and state requirements that are legally applicable or
relevant and appropriate to the remedial action.
Because the ESD does not fundamentally change
the interim remedy, the Applicable or Relevant and
Appropriate Requirements discussion presented in
the IROD is not reevaluated in this ESD. This
interim remedial action does not constitute the final
remedy for the HTF and the statutory preference
for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element
will be addressed by the final response action. A
final remedial action will be evaluated and
conducted in the firture for the entire HTF OU according to the requirements of the FFA.
Based on information currently available, the lead
agency believes the selected remedy provides the best balance of tradeoff among the other
alternatives with respect to the evaluation criteria.
The USDOE expects the selected remedy to satisfy
the statutory requirements in CERCLA Section
121(b) to: (1) be protective of human health and
the environment and (2) be cost-effective. In
accordance vrith Section 121(c) of CERCLA and
NCP §300.430(f)(5)(iii)(c), a statutory review will
be conducted within S years of initiation of the
remedial action, and every 5 years thereafter, to
ensure that the interim remedy continues to be
protective of human health and the envirorunent.
VI. PUBLIC PARTICIPATION
The public will be informed of the changes to the
selected remedy as specified in this ESD through
mailings of the SRS Environmental Bulletin, a
newsletter sent to approximately 3,500 citizens in
South Carolina and Georgia, and through notices in
the Aiken Standard, the Allendale Citizen Leader,
the Augusta Chronicle, the Barnwell People-Sentinel, and The State newspapers.
To obtain more information concerning this ESD,
contact: Amy Joslin Savannah River Remediation, LLC Dir. of Public Affairs & Project Communication Savannah River Site Building 766-H Aiken, South Carolina 29808 (803)208-1956 [email protected]
VII. REFERENCES
DHEC_01-25-1993, Sadler, M. F., Construction Permit #17,424-IW for F and H-Area High-level Radioactive Waste Tank Farms (SCDHEC Bureau of Water, Permit to Construct), South Carolina Department of Health and Environmental Control, Columbia, SC, Rev. 0, January 25, 1993.
DOE/SRS-WD-2014-001, Basis for Section 3116 Determination for Closure of H-Tank Farm at the Savannah River Site, Savannah River Site, Aiken, SC, Rev. 0, December 2014.
SRNS-RP-2012-00146, H-Area Tank Farm Groundwater Monitoring Plan and Sampling and Analysis Plan, Savannah River Site, Aiken, SC, Rev. 1, November 2012.
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SRR-CWDA-2010-00128, Performance Assessment for the H-Area Tank Farm at the Savannah River Site, Aiken, SC, Rev. 1, November 2012.
SRR-CWDA-2011-00022, Industrial Wastewater General Closure Plan for H-Area Waste Tank Systems, Savannah River Site, Aiken, SC, Rev. 0, May 2012.
SRR-CWDA-2014-00086, Industrial Wastewater Closure Module for the Liquid Waste Tank 12HH-Area Tank Farm, Savanriah River Site, Savannah River Site, Aiken, SC, Rev. 0, May 2015.
SRR-CWDA-2015-00074, Addendum to the Industrial Wastewater Closure Module for Liquid Waste Tank I2H H-Area Tank Farm, Savarmah River Site, SRR-CWDA-2014-00086, Revision 0, May 2015, Savannah River Site, Aiken, SC, Rev. 0, October 2015.
SRR-CWDA-2015-00157, Interim Record of Decision Remedial Alternative Selection for the H-Area Tank Farm, Waste Tank 16, Savannah River Site, Savannah River Site, Aiken, SC, Rev. 1, July 2016.
SRR-CWDA-2016-00095, Interim Corrective Measures Implementation/Remedial Action Implementation Plan (ICMI/RAIP) for the H-Area Tank Farm, Waste Tank 16 (U), Savannah River Site, Aiken, SC, Rev. 0, September 2016.
WSRC-OS-94-42, Federal Facility Agreement for the Savannah River Site, Administrative Docket No. 89-05-FF (Effective Date: August 16, 1993).
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SOUTH CAROLINA JUIanta ^Columbia
Aagasta ^
GEORGIA ^iavaimalt
. •^Cbariastom i'f'-
J'
-3
0 50 100 1 1 1 1—
A N 200 Miles
—I
• Miles CD.51 2 3 4
N
Figure 1. Location of the Savannah River Site
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Figure 2. Layout of the General Separations Area
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242-25H (3H) / Evaporator
Catch Tank
242-16H (2H) Evaporator System
Figure 3. General Layout of the H-Area Tank Farm
Workins Slab MiMmidification
Durt
h 75' - 0" Primary -| [NOT TO SCALE]
Figure 4. Cross-Sectional View of Typical HTF Type 1 Tank
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2Jp{l7 dd Dat6 /_ Mich«l Af^ikolanis
Assistant Manager for Infrastructure and Environmental Stewardship 1/ U. S. Department of Epcrgy
5l2oln Date
Franklin E. Hill Director Superfund Division U. S. Environmental Protection Agency - Region 4
DaphntfON^l Daphm Bureau Chief Bureau of Land and Waste Management South Carolina Department of Health and Environmental Control